This privacy notice gives you information about how Hemsley Fraser Group Limited collects and uses your personal data through your access to and use of this website, our learner portals or Digital Hub(s). 

Controller

Hemsley Fraser Group Limited is the controller and responsible for your personal data (collectively referred to as, “Hemsley Fraser”, "we", "us" or "our" in this privacy policy).

Hemsley Fraser Group Limited is a learning and development provider predominantly serving the business-to-business market. We are registered in England and Wales No: 02638042.
Our VAT registration number is GB 777 3270 03. Our data protection registration number is Z5610077.

Our registered address is BLOCK Plymouth, 23 Melville Building, Royal William Yard, Plymouth, PL1 3RP

We have appointed a data privacy manager to oversee compliance with this Privacy Policy.  If you have any questions concerning this policy, personal information that we hold on you, how to change your personal information or make a complaint please contact compliance@hemsleyfraser.co.uk

1. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you, including:

• Identity Data: your name, job title and organisation.
• Contact Data: Email address, telephone number and address.
• Financial Data: Payment and bank card details.
• Transaction Data: Products/services purchased, bookings made.
• Technical Data: IP address, browser type, login data, time zone, platform.
• Profile Data: Username, preferences, feedback, survey responses.
• Usage Data: Page views, interaction with website and Digital Hub.
• Marketing and Communications Data: Preferences in receiving communications.
• Sensitive Data: On rare occasions, health and religious data (only if necessary).

2. How is your personal data collected?

We use different methods to collect data from and about you including:

• Through your use of our website (for example, when you register as a user, browse, fill in a 
  form, use the webchat feature) or our Digital Hub
• When you make enquiries for or purchase our products our services.
• Through information gathered from publicly available sources such as websites or LinkedIn.
• Through list owners who offer UK GDPR-compliant data on decision-makers in companies, we would like to promote our products and services.
  
  

3. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example to communicate with you about relevant information and opportunities relating to courses and services which we think may be of interest to you.

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing 

We may use your data for direct marketing purposes, which includes contacting you by email, telephone text, or post with information, news and offers on our products and/or services. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under UK data protection law.

All direct marketing communications are restricted to those of a business-to-business nature, being professionally relevant to the function and roles of the data subjects and being inclusive of an easy option to opt-out from our communications at any point in time. 

Opting out of marketing 

The opt-out process can be achieved by post, email or telephone or by simply unsubscribing using the link in our emails. You will then be suppressed immediately from any future communications based on your specific preferences. Please however be aware that we will still need to retain basic information concerning the suppression so as ensure that the data subject is not sourced via alternative means and then subsequently re-entered back into our database.

Cookies

For more information about the cookies we use on our website and how to change your cookie preferences, please see our Cookie Policy.

4. Disclosures of your personal data

We may disclose your personal information to the following third parties (who may be within or outside the UK or European Economic Area) to answer your enquiries, to perform and administer the contract we enter with you in accordance with our Terms and Conditions and to process payments.

The third parties are as follows:

• Our associated companies including any member of the Hemsley Fraser group of companies which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• Our third-party service providers, sub-contractors, suppliers and professional advisors including but not limited to; payment processing, search engine optimisation, web analytics and marketing services such as email marketing or outbound telemarketing.
• Successors in title to our business. Any new controlling party will only be permitted to use the data for the exact same purposes for which it was originally collected. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
• Any organisation or person expressly instructed by you.
• Any relevant regulatory, governmental or law enforcement authority as required by law.
• We may share anonymised, aggregated or statistical data which is not personal data with third parties to help us better understand our customers and target audiences. Where we share such information it cannot be used to identify an individuals.

5. International transfers

We will work to ensure that any transfer outside the UK or European Economic Area is lawful and that appropriate security arrangements apply. 

To transfer personal information to third parties in territories that do not yet retain adequate privacy laws, we will look to enter into agreements with the parties to whom we may there transfer your personal information ensuring appropriate and suitable safeguards that would be accepted as adequate within the UK and European Economic Area. 

We require that organisations outside of our group of companies who handle or obtain personal information as service providers adhere to Data Protection Agreements and acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all Data Protection Legislation and this policy.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal information for as long as we need to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements.    We will hold your personal information on our systems for as long as is necessary for the relevant activity, or if is set out in any relevant contract you hold with us. In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a client of Hemsley Fraser we will retain and securely destroy your personal information..

8. Your legal rights

• Request access to your personal data (commonly known as a "subject access request"). This enables you to request a copy of the personal data we hold about you.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes(see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• To ask us not to use your personal data to make automated decisions about you or for profiling purposes.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. If you wish to exercise any of the rights set out above, please see the contact details at paragraph 9 below.

9. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our Data Privacy Manager at compliance@hemsleyfraser.co.uk

10. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11. Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. Any personal data we hold about you will be governed by our most recent privacy policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address